Review of NBN Co Wholesale Bitstream Products engagement

In December 2009, NBN Co released a wholesale products consultation paper (NBN001) to the public as part of a planned and ongoing, open industry engagement process. In their own words, they noted that:

NBN Co’s role is to realise the Australian Government’s vision for the development of a next generation national broadband network. To do this successfully, we need to consult widely to ensure our plans for the network meet the current and future needs of our wholesale customers and the wider Australian community.

Interested parties were invited to return submissions back to NBN Co for review by mid February 2010. In the meantime, NBN Co held two open industry briefing sessions, one in Sydney and the other in Melbourne, the latter of which was recorded and published online. In late March 2010, NBN Co released their summary of the collective open industry feedback and published a subset of the responses onto their website. This post is my review and summary of those submissions, or at least the subset that engaged in an open fashion and allowed their submissions to be made available to the public, for open review, against NBN Co’s own summary review.

In true analysis fashion, I’m going to start with just purely descriptive observations and then progressively move into the interpretive and predictive observations. So first the facts.

The 10,000 foot view, who responded (and who hid):

• NBN Co received submissions from just 48 interested parties (including 5 independent submissions).
• Of those submissions, only 25 parties (~50%) (of which only 1 was an independent submission) chose to participate in an open fashion and provide NBN Co with permission to publish their responses.
• The remaining 50% of the parties chose explicitly not to participate in an open fashion. These parties included:
  

  Alcatel-Lucent Australia	Hal Linstrom (Independent)	Ramin Communications Pty Ltd
  Australia Post	Huawei Technologies Australia Pty Ltd	Singtel Optus
  Dmitri Kalintsev (Acting Independent Technical Expert)	iiNet	Sunshine Coast Regional Council
  Dodo Australia Pty Ltd	IPG Photonics Communications Products	Vocus Group
  ECI Telecom	Mark Thomas (Independent)	Vodafone Hutchinson Australia
  EXFO Asia Pacific Pte Ltd	Nextep-NEC Australia Pty Ltd	Zinwell Australia Pty Ltd.
  FibroLAN Ltd	Nicholas Brown (Independent)
  Foxtel	Primus Telecom Australia	FTTH Council Asia-Pacific

A notable exception was the FTTH Council Asia-Pacific, who originally submitted their proposal publicly, however it was later removed by NBN Co “at the request of the FTTH Council after it expressed concern that despite the disclaimers that some of the points were not consensus views, some of its members were being associated with these views. This conveyed an incorrect impression and in the interest of its general membership the document has been withdrawn”.

What about content?
Out of the original 25 publicly accessible responses,

• 5 (20%) were less than 3 pages and contained little content,
• 10 (40%) were of a moderate size and contained summary position content and
• 10 (40%) were of a substantial size (10+ pages) and contained detailed content.

Industry knows not to bite the hand that feeds it:
When NBN Co released their summary response, they proudly announced to the public that everyone is pretty much happy with what they are planning, specifically

noting that key elements of its design and wholesale product offer for the proposed National Broadband Network have received significant industry support.

Recall that NBN Co are the Government granted future monopoly provider of broadband access in Australia, with a plan to invest approximately AUD$43 billion over the next 8 years. They represent the largest infrastructure project ever undertaken in Australia. On that basis, it is not at all surprising to see the vast majority of respondents vying with each other to position themselves as NBN Co friendly and supportive. Either to offset some inherent threat (existing infrastructure providers) or to secure some benefit (as a future direct customer, partner, supplier or some other beneficiary) from NBN Co itself.

In fact, very few of the submissions could reasonably claim to be completely impartial and hence openly objective in their feedback. Amongst these were most probably the 5 independent submissions

• Dmitri Kalintsev,
• Hal Linstrom,
• Mark Thomas,
• Michael S Cox,
• Nicholas Brown

and the various industry group submissions

• APCO Australasia,
• ATUG,
• Broadcast Australia,
• Communications Alliance,
• Free TV Australia,
• FTTH Council Asia-Pacific (Document WITHDRAWN),
• Internet Society of Australia,
• Standards Australia.

How many unbiased submissions?
In summary:

• a grand total of maybe 13 (25%) independent and impartial voices
• of which only 8 (16%) were prepared to go on public record with their feedback and
• of which only 5 (10%) provided substantive and detailed responses.

This feedback process should not have been considered as a democratic voting system with all voices being equal; rather increased attention should have been given to the clearly independent responses. If anything, those 5 responses (ATUG, Broadcast Australia, the FTTH Council Asia Pacific, The Internet Society of Australia and Michael S Cox (independent)) mentioned above should represent the strongest voices of impartial, expert opinion. Was this the case though? Is it clear from their report, that everyones voice was really heard and listened to, especially if they were being constructively critical? Well, let’s take a look and see.

The ground level view, summaries of each public respondents feedback:
For each party that submitted a publicly open response, I’ll provide a link to that response, an overview of the basic position they adopted within their response and any pertinent details that I believe are worth highlighting. Remember, these are merely my summaries of my interpretation of their responses. Nothing more, nothing less. If you wish to verify the facts, then please check their published responses.

AAPT: submitted an 8 page response, fundamentally representing their commercial interests in becoming a future RSP customer of NBN Co to provide their own retail and wholesale aggregation services. AAPT supported NBN Co’s decision to focus on layer-2 product wholesale. AAPT supported in concept NBN Co’s approach to implementing POIs but noted “how critically important the location of the PoIs to the industry” is, further noting “that POIs should at least in the first instance be located at or near existing local access switches and other POIs for ULLS and LSS products”. AAPT closed with the comment that “This issue is too important to get wrong and the best way to avoid making mistakes is to have an open and transparent consideration of the appropriate location for the POIs”, interestingly this aligns very well with Telstra’s own response regarding POI locations and numbers (see below).

APCO Australasia: submitted a 2 page response, fundamentally representing public interests (for Public-Safety Communications). APCO noted that broadband services “should be declared as ‘critical infrastructure’ in order to provide ‘mission critical services’”. APCO want to work “with NBN Co to develop the future role of broadband communications in Australia’s public safety communications”.

ATUG: submitted a comprehensive 23 page response, fundamentally representing public interests (business telecommunication service users). Fundamentally ATUG see the process of NBN as the culmination of more than a decade of Government lobbying for improved competition in the Australian telecommunications sector and the failure of policy and regulation to establish appropriate competition to date. Their focus was primarily on improving the outcomes for the end-users and in particular the business end-users. ATUG noted that “it is important that NBN Consultations include business end-users directly and Service Innovators who might not be existing telco industry members. Too much telco industry discussion focuses on innovation being driven from network infrastructure owners and operators”! Overall, ATUG were supportive of the objectives adopted by NBN Co which are mostly focused on desirable end-user and market outcomes.

Amongst some of the more interesting points raised by ATUG in their response were:

• “ATUG wants to see the development of an effective Wholesale market for Layer 3 service providers — this may require Government intervention through NBN, policy or regulation”,
• “ATUG expects to see high levels of transparency in regard to NBN wholesale pricing … (and) is not convinced by arguments for price differentials based on size of customer… Any scale economies captured by NBN Company should be shared by all end users”,
• “ATUG expects the NBN to provide a more robust base for competition in regional areas”,
• And finally, a case where ATUG were misrepresented in one of their response quotes–in particular where NBN Co re-affirmed their plan to exclude offering the LEB product in any FSA where the AEB product was being offered (which by the way affects approximately 1.5 million Australian addresses), NBN Co quoted “ATUG supports this approach to RSP competition”. In actuality, this specific ATUG quote was made directly following original text highlighting that “It is important to note that the LEB and AEB products do not provide a wholesale customer exclusive access to the ONT in the end-user’s premise. NBN Co intends to design its product offerings in a manner that allows end-users to choose multiple RSPs to supply them with retail services”. These two concepts are not the same, one is about multiple RSP delivery at the ONT, the other is about flexibility to choose a backhaul provider at the OLT, hence the NBN Co response quote is misleading in this respect.

The latter half of the ATUG response included an extract from earlier submissions they made regarding the NBN Regulatory Framework. A further interesting point comes out of this, highlighting the misquote mentioned above and reinforcing the desire for maximising choice at the infrastructure level is possible (i.e. for backhaul), namely “Choice: Competition remains a key outcome for ATUG. Where possible, infrastructure competition is preferred”! This strongly hints at permitting backhaul competition rather than declaring a backhaul monopoly.

Brisbane City Council: submitted a 5 page letter response, fundamentally representing the public interests (for their local electorate of Brisbane). Brisbane City Council (BCC) noted that NBN Co should not only “focus on competition and innovation at the retail service provider level” but should also focus on “the ability of end-users to connect directly with other end-users … providing maximum opportunity for end-users to innovate and create new applications and business opportunities across the network”. They further quote from an OECD report in their response noting that “Government should promote network technologies and topologies which are the most flexible, create the most opportunities for competition, offer the highest potential for innovation”.

Controversially, BCC were not supportive of a PON network topology and would rather that NBN Co “rollout a point-to-point fibre network”, arguing that increasing bandwidth requirements and increasing demand for symmetric upstream connectivity in the future were key justifications for avoiding a GPON deployment. They were pretty much alone in this matter. Finally, BCC close their response with a discussion on the need for clarity around backhaul for greenfield developments and in particular who should fund the costs of construction.

Broadcast Australia: submitted a 7 page whitepaper addressing “Terrestrial Broadcasting and TV Content Delivery on the NBN” as their response, representing the general interests of the broadcasters. This was a very interesting read as in short the TV industry in Australia believes that NBN Co should not implement an RF overlay as it would represent an unjustified additional cost. They were unanimously supported by the Free-to-air TV broadcaster in this matter as well. Given that together, they are the industry and they have spoken, I’d say this question of RF overlay, has been decided.

Broadcast Engineering Services: submitted a 2 page response representing their experience as a competitive broadband access service provider (HFC and FTTH (GEPON) based) in greenfield estates. Broadcast Engineering Services (BES) raise a number of questions around decision points for point-to-point versus PON, they generally agree with the layer-2 implementation approach and finally request some clarity around the definition of POIs and POI location in outer-urban greenfield estate developments.

CITT Ltd: submitted a 13 page response which fundamentally presented their concerns and interests in ensuring appropriate training and skills development to meet the extensive demand for workers that NBN Co are going to generate as part of their aggressive 8 year network construction plan. CITT call on NBN Co to support the undertaking of “a feasibility study on the Telecommunications Workforce development and planning”.

Communications Alliance: submitted a single page response congratulating NBN Co on publishing their first consultation paper, congratulating themselves for their NBN Project which has been operating for 10 months and noting that they “look forward to progressing the project’s working groups examining other aspects of the NBN, with a firm expectation that these findings and options will also be reviewed in future consultation papers”. The Communications Alliance (CA) represent the combined interests of Telecommunications operators and their vendors (basically the same aforementioned companies, who submitted responses directly, many of them privately). It is somewhat surprising that these same companies felt so compelled to offer their feedback directly in addition to the supposed “consensus position” being worked on and put forward by the Communications Alliance. Do the Communications Alliance workgroups really represent the agreed position and opinions of their members and if not, then what do they represent?

Free TV Australia: submitted a 2 page letter response which represented the commercial interests of all the Free-to-air (FTA) television broadcasters in Australia. In short, their position supported the Broadcasting Australia position and re-affirmed the desire to avoid an RF overlay implementation by NBN Co.

FTTH Council Asia-Pacific (submission REMOVED): originally submitted a 15 page detailed response, which was subsequently removed by NBN Co from their public response list, citing “The document was removed at the request of the FTTH Council after it expressed concern that despite the disclaimers that some of the points were not consensus views, some of its members were being associated with these views. This conveyed an incorrect impression and in the interest of its general membership the document has been withdrawn”. It’s a pity as this submission contained many interesting and pertinent observations, which I will simply summarise here verbatim, in order to avoid any possible conflict or challenge (please note that other media sources have also summarised these points):

• On NBN Co assumptions, “NBN Co has settled on some assumptions which are dated and will arguably not provide the best outcome”, “While a pro-competitive/innovative stance is maintained in the document, we are concerned that the approach taken will maintain the upstream status quo and not necessarily provide a boost to either competition or innovation” and “Our reading of the document is that numerous assumptions are stated in the explanatory lead-in as fait accompli … with strategies flowing from these …. we are concerned that some of the assumptions are not a result of rigorous research”,
• On the NBN Co Layer-2 service approach, “(believe) it to be an acceptable compromise if the core active network is designed as if NBN Co’s survival depended on competing against other layer-2 providers with substantial competitive tension to drive an efficient design”,
• On the NBN Co LEB/AEB exclusivity approach, “it is not clear how the assumption that the establishment of a single PoI for any given geography ensures simplicity of design and leads to associated cost savings?” and recommend that NBN Co “Look at the concept of multiple PoIs and an NBN cloud”,
• In closing, “sufficient numbers of members had reservations about the extent of reliance on narrow industry interest groups and we would strongly recommend that NBN Co expand its consultation base to even include professional consultants as opposed to organizations made up of members with a fiduciary duty to protect their respective organizations interests. This point proved to be contentious”.

The FTTH Council Asia Pacific also had a fair bit to say on the matter of traditional FTTP deployment architectures (large FSAs concentrating into large FANs where limited POIs are provided) versus next generation micro-OLT approaches (much smaller FSAs based on a micro-OLTs resulting in far more numerous network POIs). This approach possibly deserves the merit of further discussion and analysis as it fits well with the content of Telstra’s submission and solves a fair few other problems as well (such as integrating greenfields and existing FTTP deployments). I’m not convinced that this approach is necessarily the best approach, just that it deserves some discussion.

Somewhat notably, NBN Co did not acknowledge any of FTTH Council Asia Pacific feedback in their summary response. This is unfortunate, as some of their observations are in my opinion, significant.

Fujikura Asia Ltd: submitted a 4 page response fundamentally representing their commercial interests in becoming a future supplier of passive optical components to NBN Co. Interestingly, Fujikura were quite flexible in their response, recommending that NBN Co also remain as flexible as possible in their construction and deployment practices in order to future proof the network against design changes, demand changes and technology changes.

Internet Society of Australia: submitted a 5 page response, fundamentally representing public interests and end-users (Internet end users in particular). The Internet Society of Australia (ISOC-AU) raise a number of important and unique issues in their concise response. Amongst these issues raised were:

• Concern over avoidance of Layer-3. Understandably ISOC-AU are very concerned about IP which operates at Layer-3 and hence see “that the ideal approach is one where NBN Co provides layer 2, aggregated layer 2 and layer 3 services” concurrently, noting that in the absence of offering layer 3 “NBN Co to rapidly determine and make public its OSS specifications in order to facilitate the corresponding development of retail and wholesale systems using flow through provisioning and network monitoring and management”,
• Concern over PoIs and PoI locations “ISOC-AU encourages NBN Co to offer widespread aggregation of its services in addition to the option of installing local equipment” which strongly implies support for a concurrent LEB/AEB offering as well,
• Concerns over lack of symmetry, especially with respect to IP multicast where “ISOC-AU would prefer to see two way multicast services, that is, where end users can stream multicast” up into the network, not just consume,
• Remaining general concerns over security, interception and privacy, as well as performance,
• Finally, ISOC-AU also note that “we would like to encourage NBN Co to engage further with the end user community in order to obtain the best outcomes for the network”.

Somewhat notably again, NBN Co did not acknowledge any of this ISOC-AU feedback in their summary response! This is unfortunate, as their recommendations are significant and have a material impact on decisions already concluded based on the false assumption of overall support.

JDSU: submitted a 9 page response (with a number of additional attached whitepapers) fundamentally representing their commercial interests in becoming a future supplier of strategy, design and Test and Measurement equipment to NBN Co. This submission was primarily technical marketing.

Juniper Networks: submitted a 5 page response (I suspect this was a cut-down version) fundamentally representing their commercial interests in becoming a future supplier of active network equipment to NBN Co. This submission was primarily technical marketing and focused on recommending NBN Co to follow Metro-Ethernet Forum (MEF) standards and the Broadband Forum (BBF) TR-101 report with specific attention being called to the various IGMP and QoS implementation. Juniper specifically “recommend a tiered set of performance characteristics to allow RSPs to acquire wholesale products for Internet services that can be matched, in capability and price, with the varying usage of their subscriber base”, nice call Juniper, glad to see you’re finally on the same page after nearly a decade (don’t know what I’m talking about, have a chat to your NZ team).

Macquarie Telecom: submitted a 4 page response fundamentally representing their commercial interests in becoming a future RSP customer of NBN Co. Macquarie were overall supportive of many of NBN Co draft proposals with a few exceptions. It is these exceptions that are the most interesting as they were conveniently ignored in NBN Co’s summary response. For instance, in the discussion of POI location and POI definitions (the AEB and LEB again), NBN Co quoted Macquarie Telecoms response as “Macquarie understands that the “model” refers to NBN Co’s proposed network design which will aggregate smaller FSAs to a single POI. POIs in turn are to be located on the existence of, or expectation of, competitive backhaul. Macquarie believes that such a model will in principle be conducive to RSP participation in less densely populated locations”, however NBN Co stopped quoting there whilst Macquarie clearly continued immediately with the following proviso:

on the grounds that:
- RSPs will be serviced by a willing wholesale access service provider, i.e. NBN Co; and willing backhaul providers; and
- RSPs should have a choice of backhaul provider ensuring that backhaul pricing will be competitive.

Macquarie, I could not agree with you more! This point is further reinforced with later comments such as “As traffic volumes build, commercial backhaul providers would be encouraged to increase their network capacity and/or expand their networks deeper into FSAs” which very strongly would be dependent on NBN Co opening up multiple concurrent LEB POIs.

Macquarie Telecom also went further in their submission to detail very sensible criteria for evaluating when a POI can be considered sufficiently contested and hence competitive. The table is reproduced here:

# of Suppliers	Smallest Suppliers % share of Total Capacity	Assessment
4 or more	N/A	Competitive
3	>= 20%	Competitive
3	< 20%	Not Competitive
2	>= 30%	Competitive
2	< 30%	Not Competitive
1	N/A	Not Competitive

Source: Macquarie Analysis

Michael S Cox, Independent: my submission consisted of a 27 page response which included detailed technical and strategic assessments of much of NBN Co’s published paper. The response was deliberately constructed to represent the interests of Australia residential and business users first and foremost, the evolution of a vibrant, competitive and healthy retail service provider market second and the ongoing economic viability of NBN Co as a wholesale entity third. Whilst the response was overall supportive of many of NBN Co’s proposals, objectives and assumptions; there were a few places where it was critical of various approaches being considered or adopted by NBN Co. In all of these areas, the criticisms were backed up with substantial analysis and a provably better alternative was proposed. Disconcertingly, much of this critical input was summarily dismissed with the following text in the response document:

Almost all respondents who did comment were supportive of the concept.

Some of the issues I raised included:

• Regarding layer 2 versus layer 3 services, “It is not important that these services be provided by NBN Co itself, however it is crucial that they be provided by an independent and competitive layer-3 wholesale service provider who preferably do not themselves have a internal conflict of interest through offering similar, competing applications. In order to maximise end-user benefit it will be necessary to ensure such competition evolves in the market”,
• Regarding the proposal to offer AEB exclusive of LEB, “this may be materially detrimental to the overall product objectives of supporting “differentiation and innovation by RSPs–by providing them with an experience as close as possible to owning their own network” and promoting “maximum end-user choice in terms of both services and providers”. The primary case in point here is our local community consisting of both end-users and local application service providers (community health, small business, local council, public library etc). In such areas if only a single POI is supported, in this case via the AEB product offering (with embedded backhaul component), then the local retailers and any RSP aggregator who would wish to function locally will be significantly disadvantaged by being forced to locate service infrastructure non-locally across to the aggregation POI”, closing with “On the basis of the discussion above, it is recommended that NBN Co reconsider offering LEB POI services for every FSA and where “contestable” backhaul does not exist, additionally also offering the AEB POI service to help foster open access and RSP competition”,
• Regarding the QoS specification, on the positive “It is very encouraging to see that NBN Co are considering a tiered QoS capability as this will significantly open up the market opportunities for service and price differentiation/competition” with a proviso warning that “Whilst it appears on the surface to contain all the key elements required for optimal market competition and fairness, the statements form an unclear and partially incomplete picture”.

Amongst some of the other contributions within this submission was a strategic plan for implementing the tiered QoS capabilities, detailed specifications around the performance characteristics, detailed specification of approaches to managing battery backup and a strategic engagement plan for supporting smart metering in return for access to universal power.

Motorola Australia Pty Ltd: submitted a 26 page response, fundamentally representing their commercial interests in becoming a future equipment supplier to NBN Co. For the most part Motorola are supportive of NBN Co’s proposals, noting how their equipment clearly supports the NBN Co requirements. It is noted that Motorola were completely silent on section 6, which discussed the POI locations (“Motorola does not have any comments on this”). Apart from a small diversion around facilitating layer 3 delivery by RSPs, their submission was primarily a product pitch.

NBN Workgroup New England: submitted a 2 page response, fundamentally representing their community interests as a future beneficiary of NBN Co’s construction activities. This response was clean, quick and very constructive, offering NBN Co deployment advice specific to their environment and support during the roll-out, as required.

Nextgen Networks: submitted a 13 page response, fundamentally representing their commercial interests as a future RSP customer of NBN Co and co-operative competitor on backhaul. It is important to note that Nextgen are somewhat unique in the industry as they do not actively participate in end-user retail services. Whilst Nextgen where mostly supportive of the approaches being adopted by NBN Co, they still raised at least one concern that they desired to see addressed, namely:

• Regarding POI location and AEB/LEB definition, “In particular, Nextgen considers the idea of a single POI for an FSA that migrates over time as likely to require significant customer migration activity for all the wholesale carriers purchasing services in a migrated FSA”, noting that “Nextgen would like clarity on how FSA with AEB could be migrated to an FSA with LEB” in the future.

I also highlighted this particular concern, along with several others which were supported by other respondents including Telstra, Macquarie Telecom, FTTH Council Asia Pacific, ATUG, and ISOC-AU. I’m detecting a common theme now, surrounding any challenges or questions made against the definition of the AEB/LEB construct. In their response NBN Co note that

the AEB/LEB construct and proposed product conditions did not generate a significant amount of detailed industry comment. Almost all respondents who did comment were supportive of the concept.

Why am I no longer convinced that this actually was the case? Is it possible that we may need a few extra checks and balances, just to make sure that the right actions are being taken? I know that when someone else is spending my money for me, I want to know that they are spending it in the right places. This is the part of the process that is referred to as “being transparent”.

And this is admittedly, just a little minor thing, something simple and almost obvious. What about the more major and complex issues, such as pricing structures?
Addendum: After much debate and discussion, I’m willing to concede that maybe this point isn’t quite as obvious and simple as I may have originally thought.

Aside: Mickey and Stefan, I truly hope you’ve remembered everything from our discussions, as the devil really is hidden in the details (beware of compromises as they often lead to complete collapse)–and good luck, I fear you are going to need it in your battles.

Ramsden Telecommunications Training: submitted a 3 page response, fundamentally representing their commercial interests as a future supplier of skills training services to support NBN Co’s construction activities. This response was simply a capability statement for Ramsden Telecommunications.

Standards Australia: submitted a 5 page response, fundamentally representing the personal views of their Chair, Mr. John Ward. Mr. Ward apologised for the lack of formal response by the industry group, claiming that this was due to the timing of the response being coincidental with the Australian summer holidays. Mr. Ward however, goes on to make some interesting recommendations and observations, amongst these are:

• A strong recommendation for technology agnostic home network cabling implemented in accordance with strict standards to accommodate current and future bandwidth requirements,
• A strong recommendation to avoid ‘cost minimisation’ and focus more on maximising end users service capability,
• A strong recommendation to allow selective bandwidth purchasing of QoS across any service capability.

Most interestingly though, Mr. Ward closes the final section with

There is a distinct underlying tone throughout the entire document that NBN Co. knows best and is only offering this solution and only requiring endorsement of same–whilst calling for minor/token adjustments/refinements of same!

Very astute observation there Mr. Ward, you may very well have been right.

Symbio Networks: submitted an 8 page response, fundamentally representing their commercial interests in becoming a future equipment and service supplier to RSPs for the provision of voice services over IP. This is an interesting response as Symbio have vested interest in seeing NBN Co not integrate the VoIP ATA (the capability for supporting plain old telephony services) into the ONT (the shoe-box on the customer premise wall). Rather, they desire to see the voice service completely decoupled from the access service in order to ensure ongoing market opportunities for their service. They argue quite strongly for this decoupling but also provide key recommendation if the service is to be integrated. I’m going to keep out of this argument unless someone wants an opinion. In short the Symbio position is a heavily biased one, however they do understand their service and what they are talking about.

Tech Mahindra Ltd: submitted a 46 page tome, fundamentally representing their commercial interests in providing professional services, integration, design and consulting to NBN Co. This is a fairly detailed technical/marketing document which covers vast aspects of NBN Co’s wholesale product engagement and much more beyond, which takes it outside of the scope of the original engagement. Summarising it really requires a separate post, so I’m going to pick out a few observations:

• They recommend that the voice ATA avoid being based on SIP and instead use MeGaCo/H.248 which is unusual,
• They recommend a flexible packaging hierarchy of wholesale products (‘telescopic consumption model’), that would allow RSPs complete flexibility and control of how they purchase/bundle various product attributes which is sensible,
• They recommend that NBN Co consider a number of alternative approaches to coupling backhaul with AEB and that NBN Co engage openly with industry in determining the best model and locations which is sensible,
• They provide guidance and recommendation on processes, systems, OSS and vendor management which is really out of scope.

There’s probably a lot more that I could say, but not really much more value that I can add, beyond the above.

Telstra: submitted a 16 page response, fundamentally representing their commercial interests as a combined competitor, customer and potential provider/partner to NBN Co (I wouldn’t want the problem of having to counter-balance those conflicting interests). Telstra–Australia’s largest and incumbent Telecommunications operator and arguably the primary cause of why NBN Co exist in the first place. Telstra’s submission covered substantial territory, especially considering its size, ranging from areas of agreement, areas of support and areas of disagreement. Where Telstra disagreed with NBN Co, they backup up their position with substantial evidence and logical argument. Amongst many of the comments, observations and issues raised by Telstra, were:

• Telstra disagreed very strongly with the proposed AEB/LEB construct as well as the proposed limited number of POI locations (approx 200 nationally according to NBN Co, Telstra argue that it should be closer to 600-900 and others argue for somewhere around 350 (where ULL DSLAMS are)). They supported their arguments with a range of business impact statements, referred to specific trade obligations as part of our commitments to the WTO and provided statements identifying how such implementations go against the guiding objectives of the Governments NBN plan. Several other responses also concurred with many of these statements to no avail.
• Telstra agreed in principle with all of NBN Co’s stated product objectives, whilst noting that some of NBN Co’s product offerings fail to actually achieve the stated objectives. Several other responses also concurred with these statements to no avail.
• Telstra agreed with NBN Co’s plan to offer services at layer-2, noting that a healthy market for layer-3 aggregation and wholesale already exists within the market. The responses were mixed on this issue.
• Telstra agreed with the proposed Ethernet/GPON network for mass residential services and noted that certain exceptions would justify point-to-point dark fibre solutions.
• Telstra agreed with most of the various technical detail points, indicating in-principle support for the various bandwidth, QoS, battery-backup, SIP ATA and other product elements.
• Telstra did make a recommendation for NBN Co to consider offering an RF overlay service and integrating an RF port into the ONT, despite the fact that the broadcast television industry responses clearly indicated that this was not the desired approach.

In closing, “Telstra encourage(d) NBN Co to consult further with the industry on matters such as those raised above to best achieve its stated outcomes and to maximise the consumer benefits that will be derived from its proposed wholesale offerings”. All-in-all, a very well presented, well constructed and well argued response and most certainly not what I expected.

TITAB Australia: submitted a 14 page response, fundamentally representing the commercial interests as a future supplier of training services to support the NBN Co construction activities, however their response did take into account wider community issues. TITAB indicated on several points of discussion that they believed the issues were impacted by yet-to-be-determined policies, required further consultation with their members or would be better addressed by others in the industry. TITAB indicated that they were participating and supporting both ATUG and the Communications Alliance in their various NBN workgroups.

TransACT: submitted a 3 page response, primarily representing their commercial interests as an impacted party and potential supplier of infrastructure to NBN Co. Briefly, the TransACT response indicated that due to time constraints they were not able to offer a detailed response, however they in principle agreed with the layer-2 delivery model and their guiding product objectives. TransACT closed with the recommendation that “The network needs to be a true open access ubiquitous network that supports the delivery of both existing and next generation services and applications, priced to encourage acceptance and utilisation by service providers with equivalence of access”.

Conclusion:
In their own words,

NBN Co is committed to an open and inclusive consultation process with its future customers to develop the network and products that meet their technical and commercial requirements.

Yet, despite this, many of NBN Co’s ongoing engagements are becoming increasingly selective and closed, increasingly prescriptive in terms of engagement, either invite only and/or subject to non-disclosure. This is contrary to the strong recommendations of almost all the independent bodies to further open up and engage the general public in addition to the vested interest bodies.

NBN Co, the ball is now squarely in your court. This project is far too important and far too large to risk making avoidable mistakes, especially when there is a huge body of untapped industry experts out there both able and willing to help. All you need to do, is to engage them openly and constructively. Maybe together, we can truly achieve the best outcome?

Disclosure Statement: I neither work directly nor indirectly for either Telstra or NBN Co. I am completely impartial in this matter and have been since the industry engagement began. If you wish to contact me for further information, please see my contact page.